icoDealDeck.com — Know Your Customer/ Customer Due Diligence Policy

Purpose: The purpose of KYC/CDD is to prevent financial services providers from being used, intentionally or unintentionally, by criminal elements for money laundering activities.

KYC/CDD policies enable financial services providers to know or understand their customers and their financial dealings.

Overview: The KYC/CDD Policy identifies the specific customer and transaction information collected and recorded, as well as the verification of customer identification and government filings in accordance with regulatory expectations.

Summary: icoDealDeck.com (“icoDealDeck.com”) collects and records certain information from every customer that completes a transaction, utilizes a risk-based approach to verify the identity of certain customers, and records transaction information, customer identification, and verification methods. icoDealDeck.com has implemented a tiered system based on transactional amount to determine, at minimum, the pieces of information and identification to be collected and verified. Additionally, icoDealDeck.com leverages this information to perform OFAC and other watchlist screening of all customers, as well as CTR filings for transactions in excess of $10,000.

In situations where either a customer sends multiple transactions within a single business day, icoDealDeck.com will aggregate the transactions and apply the aggregated amount to its tier system.

Exceptions: icoDealDeck.com will not grant any exceptions to its KYC/CDD Policy.

icoDealDeck.com will not execute the customer-requested transaction under the following circumstances: (1) the customer is unable to provide the requisite information, (2) the customer is unable to present an unexpired government-issued photo identification when required, or (3) icoDealDeck.com is unfamiliar with the type of identification presented.

If a prospective or existing customer either refuses to provide the information described below upon request or appears to have intentionally provided misleading information, icoDealDeck.com will not conduct the transaction and, after considering the risks involved, may block all future customer transactions. In either case, the BSA compliance officer will be notified and determine whether a Suspicious Activity Report (“SAR”) is warranted.

Details: The KYC/CDD tiers are as follows.

Tier 1 (transactions <$1000)

icoDealDeck.com will collect and record the following information from any customer that purchases ICO tokens in amounts less than $1000.

(1) Full name

(2) Phone number

(3) Ethereum wallet address

(4) Transaction amount

(5) Transaction date

(6) Transaction time

(7) Transaction location

Additional action(s):

(I) Natural language processing, named entity recognition

(II) Phone number verification

(III) OFAC screening

(IV) Other watchlist screening

Tier 2 (transactions $1,000 — <$10,000)

icoDealDeck.com will collect and record the following information from any customer that completes a purchase of ICO tokens in amounts ranging from $1,000 to <$10,000.

(1) Full name

(2) Phone number

(3) Date of birth

(4) Ethereum wallet address

(5) Transaction amount

(6) Transaction date

(7) Transaction time

(8) Transaction location

Additional action(s):

(I) Natural language processing, named entity recognition

(II) Phone number verification

(III) OFAC screening

(IV) Other watchlist screening

(V) Review blockchain explorer data

Tier 3 (transactions >$10,000)

icoDealDeck.com will collect and record the following information from any customer that completes a purchase of ICO tokens in an amount greater than $10,000.

(1) Full name

(2) Phone number

(3) Address

(4) Date of birth

(5) Government-issued identification, unexpired

(6) Ethereum wallet address

(7) Transaction amount (U.S. Dollar; bitcoin)

(8) Transaction date

(9) Transaction time

(10) Transaction location

Additional action(s):

(I) Natural language processing, named entity recognition

(II) Phone number verification

(III) OFAC screening

(IV) Other watchlist screening

(V) Review blockchain explorer data

(VI) Verification of customer information, including identification

(III) Referral for enhanced due diligence (EDD) review

(IV) Filing of a Currency Transaction Report (“CTR”)

Records: icoDealDeck.com will retain the aforementioned records relating to its KYC/CDD Program and any supporting records. icoDealDeck.com will retain these records for at least five (5) years after the date of transaction. These records will be filed or stored in such a way as to be accessible within a reasonable period of time.

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ICODEALDECK.COM IS NOT REGISTERED TO PROVIDE INVESTMENT ADVICE AND IS SIMPLY PROVIDING AN OPINION, BASED ON OUR EXPERIENCE, WHEN DISCUSSING TOKENS. INFORMATION CONTAINED HEREIN IS NOT AN OFFER OR SOLICITATION TO SELL, BUY OR HOLD ANY SECURITY.
ICODEALDECK IS NOT A BROKER-DEALER OR FINANCIAL ADVISER AND IS NOT AFFILIATED WITH AN INVESTMENT ADVISORY FIRM. ICODEALDECK AND/OR ANY COMPANIES AFFILIATED WITH ICODEALDECK ARE NOT RESPONSIBLE FOR ANY GAINS OR LOSSES THAT RESULT FROM THE OPINIONS EXPRESSED HEREIN.
ICODEALDECK MAKES NO REPRESENTATION AS TO THE COMPLETENESS, ACCURACY, OR TIMELINESS OF THE MATERIAL PROVIDED AND ALL MATERIALS ARE SUBJECT TO CHANGE WITHOUT NOTICE.
THE TOKENS DISCUSSED HEREIN HAVE NOT BEEN REVIEWED BY THE SECURITIES AND EXCHANGE COMMISSION OR ANY STATE SECURITIES REGULATORY AUTHORITY. FURTHERMORE, THE FOREGOING AUTHORITIES HAVE NOT CONFIRMED THE ACCURACY OR DETERMINED THE ADEQUACY OF THE TOKEN OFFERING DOCUMENTS. ANY REPRESENTATION TO THE CONTRARY IS A CRIMINAL OFFENSE.
THE TOKENS IDENTIFIED HEREIN MAY CONSTITUTE SECURITIES PURSUANT TO FEDERAL AND STATE SECURITIES LAWS AND MAY NOT BE APPROPRIATE FOR, OR OFFERED TO, INVESTORS RESIDING IN THE UNITED STATES. IN MAKING AN INVESTMENT DECISION, INVESTORS MUST RELY ON THEIR OWN EXAMINATION OF THE PERSON OR ENTITY ISSUING THE TOKEN AND THE TERMS OF THE OFFERING, INCLUDING THE MERITS AND RISKS INVOLVED. INVESTORS IN TGOKENS SHOULD CONSULT THEIR FINANCIAL ADVISER BEFORE INVESTING IN TOKENS.
THE SECURITIES AND EXCHANGE COMMISSION HAS WARNED INVESTORS RESIDING IN THE UNITED STATES THAT TOKENS MAY CONSTITUTE SECURITIES, AND BY INVESTING IN TOKENS, INVESTORS MAY BE PURCHASING UNREGISTERED SECURITIES. INVESTORS IN TOKENS MAY BE UNABLE TO RECOVER LOSSES SUSTAINED IN THE EVENT OF FRAUD OR THEFT.